Canada: $444 Million Investment to “Crack Down” on Tax Evasion
The Panama Papers obviously did not go unnoticed. The OECD recently stated that "Tax administrations [are] ready to act on “Panama Papers”" in this Communiqué. In Canada, the Government of Canada indicated this morning: "The Government of Canada...
Posted by DRTP
On 11 April 2016
USA: Additional Actions Against Inversions and Earnings Stripping
The U.S. Treasury and the IRS recently indicated: "Today, Treasury is taking action to: · Limit inversions by disregarding foreign parent stock attributable to recent inversions or acquisitions of U.S. companies. This will prevent a foreign company (including...
Posted by DRTP
On 11 April 2016
OECD: Consultation Document on the Treaty Entitlement of non-CIV Funds
Paragraph 5 of the paper explains: "This consultation document has been produced as part of the follow-up work on this issue [address adequately the treaty entitlement of non-collective investment vehicles (CIV) funds]. It includes a...
Posted by DRTP
On 25 March 2016
Practice Makes Perfect: IRS Releases New International Practice Units
Since our last blog post on the matter, the IRS has been busy releasing 10 new practice units: 03-18-2016 Inbound Resale Price Method Routine Distributor 03-18-2016 Computing Foreign Base Company Income for US Individual Shareholders...
Posted by DRTP
On 23 March 2016
Transfer Pricing in Canada: CbC Reporting is Here; and it’s not alone
Note pour nos lecteurs francophones : tous les détails de ce billet sont disponibles en français sur cet hyperlien : http://www.budget.gc.ca/2016/docs/tm-mf/si-rs-fr.html The March 22, 2016 Federal Budget indicates: "Consistent with the recommendations of the BEPS project,...
Posted by DRTP
On 22 March 2016